Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax and an addition to tax under section 294(d)(1)(A) of the Internal Revenue Code of 1939, for the year 1952, in the respective amounts of $25,367 and $2,283.05.
The issues for decision are as follows: (1) whether certain shares of stock issued to petitioner in 1952 as compensation had a determinable...
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